Companies House SECR Rejection: Common Mistakes to Avoid

Few experiences are more frustrating for company secretaries and compliance managers than having your carefully prepared annual accounts rejected by Companies House. When SECR (Streamlined Energy and Carbon Reporting) disclosures are incomplete, incorrect, or missing entirely, your statutory accounts filing can be rejected—triggering delays, additional costs, and potential late filing penalties.

The good news? SECR rejections are entirely avoidable. This comprehensive guide walks through the 10 most common SECR mistakes that trigger Companies House rejections, with practical examples and solutions to ensure your filing is accepted first time, every time.

Understanding Companies House SECR Enforcement

How Does Companies House Review SECR Disclosures?

Companies House has implemented a combination of automated checks and human review to identify non-compliant SECR reporting:

Automated flags:

• Missing SECR sections when company size indicates it should be required
• Accounts submitted by qualifying companies (50+ employees, £36M+ turnover or £18M+ balance sheet) without identifiable SECR content
• Incomplete data fields (e.g., emissions reported but no intensity ratio)

Human review triggers:

• Automated flags route accounts to specialist reviewers
• Random sampling of accounts from qualifying companies
• Previous rejection history (companies with past SECR issues face increased scrutiny)

What Happens When Your SECR is Inadequate?

Initial rejection:

1. Companies House issues a rejection notice specifying the deficiency
2. You have a limited timeframe to correct and resubmit (typically 14 days)
3. If you miss the original statutory filing deadline during this process, late filing penalties apply

Late filing penalties for private limited companies:

• Up to 1 month late: £150
• 1-3 months late: £375
• 3-6 months late: £750
• Over 6 months late: £1,500

For public companies, penalties are higher (up to £7,500 for persistent delays).

Reputational impact:

• Visible public record of late filing on Companies House website
• Stakeholder scrutiny (investors, lenders, clients may view as governance failure)
• Regulatory attention (HMRC and other agencies may increase oversight)

How Common Are SECR Rejections?

Based on industry data and practitioner experience:

• Overall SECR rejection rate: Approximately 2-3% of qualifying companies (up from <1% in 2020-2022)
• First-time SECR filers: Higher rejection rate (~5-8%) due to unfamiliarity
• Repeat filers: Lower rate (~1-2%) as processes improve
• Automated platform users (like Comply Carbon): Near-zero rejection rate (0.1% or less) due to built-in compliance checks

The rising rejection rate reflects Companies House's increased enforcement focus following the Economic Crime and Corporate Transparency Act 2023.

The Top 10 SECR Mistakes That Trigger Rejection

Mistake 1: Missing SECR Section Entirely

The error: Qualifying companies submit accounts with no SECR disclosure at all.

Why it happens:

• Company doesn't realize SECR applies (confusion about thresholds)
• Accountant forgets to include SECR in Directors' Report
• Copy-paste from prior year template before SECR was required

How to avoid:

• Check thresholds annually: Even if you weren't required last year, growth may trigger requirements this year
• Use a checklist: Ensure Directors' Report includes SECR section before finalizing accounts
• Flag in your accounting timeline: Add "Compile SECR data" as a specific milestone 6-8 weeks before accounts deadline

Example rejection notice:

"The Directors' Report does not include the Streamlined Energy and Carbon Reporting (SECR) disclosure required under the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018. The accounts have been rejected. Please amend and resubmit within 14 days."

How to fix:

1. Prepare SECR disclosure covering the reporting period
2. Insert new section in Directors' Report (typically 1-2 pages)
3. Re-issue Directors' Report with updated signature and date
4. Resubmit full accounts package to Companies House

Mistake 2: Incomplete Emissions Data (Scope 1 or Scope 2 Missing)

The error: Reporting only electricity (Scope 2) while omitting natural gas or transport fuels (Scope 1), or vice versa.

Why it happens:

• Misunderstanding of Scope 1 vs. Scope 2
• Data collection gaps (forgot to request gas bills, or don't track fuel for company vehicles)
• Incorrectly claiming exemption (e.g., "we don't have Scope 1" when gas heating exists)

How to avoid:

• Understand the scopes:
  • Scope 1: Fuel combustion you control (gas, oil, LPG, petrol/diesel in company vehicles)
  • Scope 2: Purchased electricity
• Audit all energy sources: Walk through your facilities and vehicles to identify every energy input
• Collect comprehensive bills: Gas, electricity, and any other fuels

Example of incomplete reporting:

"Total energy consumption: 350,000 kWh (electricity). Scope 2 emissions: 67.6 tCO2e."

Problem: No mention of Scope 1. Unless the company is all-electric (rare), this suggests gas heating or other fuel use has been omitted.

Correct version:

"Total energy consumption: 350,000 kWh electricity, 180,000 kWh natural gas. Scope 1 emissions (natural gas): 36.5 tCO2e. Scope 2 emissions (electricity): 67.6 tCO2e. Total: 104.1 tCO2e."

Special case: All-electric operations:

If you genuinely have zero Scope 1 emissions (all-electric building, no company vehicles), state this explicitly:

"The company operates entirely on purchased electricity with no direct fuel combustion. Scope 1 emissions: 0 tCO2e. Scope 2 emissions: 67.6 tCO2e."

Mistake 3: Missing or Inappropriate Intensity Ratio

The error: No intensity ratio reported, or an intensity ratio that makes no sense for the business.

Why it happens:

• Overlooking the mandatory intensity ratio requirement
• Choosing an irrelevant denominator (e.g., emissions per product unit when you're a service business)
• Mathematical error (denominator doesn't match business reality)

How to avoid:

• Always include at least one intensity ratio—it's mandatory
• Choose a relevant denominator:
  • Office businesses: emissions per employee (FTE)
  • Manufacturing: emissions per unit produced or per £ revenue
  • Retail: emissions per store or per square meter
  • Hotels: emissions per guest night
• Sanity-check the number: Does it seem plausible compared to prior years or sector norms?

Example of missing intensity ratio:

"Total emissions: 450 tCO2e."

Problem: No intensity metric—Companies House may reject this as incomplete.

Correct version:

"Total emissions: 450 tCO2e. Intensity ratio: 3.2 tCO2e per employee (140 FTE)."

Example of inappropriate intensity ratio:

"Intensity ratio: 0.05 tCO2e per customer."

Problem: If you're a B2B software company with 20 enterprise clients, this denominator is meaningless. "Per employee" would be far more relevant.

Mistake 4: No Energy Efficiency Narrative

The error: Reporting numbers without describing any energy efficiency actions taken.

Why it happens:

• Misunderstanding that both quantitative data AND a qualitative narrative are required
• Thinking "we didn't do anything" means you can skip this section
• Generic boilerplate that says nothing substantive

How to avoid:

• Include a narrative, even if brief—it's mandatory
• Be specific: Name actual actions taken, sites affected, quantify savings if possible
• If no major actions taken: Describe minor improvements, behavioral initiatives, or future plans

Example of missing narrative:

"Total emissions: 320 tCO2e. Intensity ratio: 2.1 tCO2e per employee."

Problem: No energy efficiency narrative—incomplete SECR disclosure.

Example of inadequate boilerplate:

"The company is committed to reducing energy consumption and continually seeks improvement opportunities."

Problem: This says nothing concrete and may be flagged as insufficient.

Correct version:

"During the financial year, the company replaced fluorescent lighting with LED in our head office (estimated 20,000 kWh annual saving) and implemented automatic power management on all workstations. We also engaged staff in a 'switch off' awareness campaign and replaced our legacy server infrastructure with cloud services. No major capital projects were undertaken, but we have commissioned an energy audit for FY2026-27 to identify further efficiency opportunities."

This demonstrates real action and planning, even without massive capital expenditure.

Mistake 5: Using Outdated or Incorrect Conversion Factors

The error: Applying conversion factors from the wrong year, or not using official UK Government factors at all.

Why it happens:

• Using a previous year's spreadsheet without updating factors
• Applying international or non-UK conversion factors
• Making up "estimated" factors instead of using official data

How to avoid:

• Download current factors: Use the UK Government GHG Conversion Factors published annually (every June)
• Match reporting period to factor year: For financial years ending in 2026, use 2025 conversion factors
• Document your methodology: State which factor year you've used in your SECR disclosure

Example of incorrect factors:

"Electricity emissions calculated using 0.25 kgCO2e/kWh factor."

Problem: The UK grid electricity factor for 2025 is 0.193 kgCO2e/kWh. Using 0.25 suggests outdated factors (pre-2020) or incorrect source.

Correct version:

"Emissions calculated using UK Government GHG Conversion Factors 2025. Electricity: 0.193 kgCO2e/kWh. Natural gas: 0.203 kgCO2e/kWh."

Red flag: If your year-on-year emissions increase despite stable energy consumption, you may have mistakenly used older (higher) conversion factors. Grid decarbonization means factors decrease over time.

Mistake 6: Implausible or Erroneous Data

The error: Reporting emissions that are obviously wrong (orders of magnitude too high or too low).

Why it happens:

• Spreadsheet formula errors (incorrect cell references, missing data)
• Unit conversion mistakes (reporting kWh as MWh, or kg as tonnes)
• Decimal point errors (450 tCO2e reported as 4500 tCO2e or 4.5 tCO2e)

How to avoid:

• Sanity check against prior year: Does this year's data make sense compared to last year?
• Benchmark against sector norms: Does your emissions intensity align with similar companies?
• Have a second person review: Fresh eyes catch errors

Example of implausible data (too low):

"Company with 200 employees in 5 UK offices. Total emissions: 3.2 tCO2e."

Problem: This is impossibly low. A 200-person office-based company typically emits 150-400 tCO2e. 3.2 tCO2e suggests a data or calculation error.

Likely cause: Reported kWh as MWh (off by factor of 1000), or only included one month instead of 12.

Example of implausible data (too high):

"Small consulting firm, 60 employees, one office. Total emissions: 8,500 tCO2e."

Problem: This is 142 tCO2e per employee—about 50x higher than expected for an office-based business. Likely decimal point error or formula mistake.

Typical office emissions: 1-3 tCO2e per employee is normal for professional services firms.

Mistake 7: Incorrect Reporting Period

The error: Reporting energy data that doesn't match the financial year covered by the accounts.

Why it happens:

• Using calendar year data when financial year differs
• Mixing data from multiple periods inconsistently
• Including partial-year data without pro-rating

How to avoid:

• Match reporting period exactly to financial year: If your accounts cover 1 April 2025 - 31 March 2026, your SECR data must cover the same period
• Align bill dates carefully: Sum bills that fall within the reporting period (may require pro-rating if billing cycle doesn't align)
• State the reporting period explicitly: "Energy consumption and emissions for the 12 months ended 31 March 2026"

Example of incorrect period:

Company financial year: 1 October 2025 - 30 September 2026 SECR data reported: January 2025 - December 2025

Problem: This is a different 12-month period. SECR must align with the financial year covered by the accounts.

Correct approach:

• Gather bills from October 2025 through September 2026
• If some bills span month boundaries, pro-rate consumption to match the exact period

Mistake 8: Incorrectly Claiming Exemption

The error: Claiming low-energy exemption when it doesn't apply, or applying other non-existent exemptions.

Why it happens:

• Misunderstanding the 40,000 kWh exemption threshold
• Thinking "we're a small office" exempts you (size matters, not nature of business)
• Believing first-year exemption exists (it doesn't—requirement starts immediately when you meet thresholds)

SECR exemptions (the only ones that exist):

1. Low energy use exemption: If you consumed less than 40,000 kWh total energy in the reporting period, you must state this but don't need to provide full emissions data
2. Subsidiary exemption: If included in parent company group SECR disclosure
3. No UK energy consumption: Companies with only offshore operations (rare)

Common misapplications:

Incorrect: "As a professional services firm with no manufacturing operations, SECR does not apply."

• Problem: SECR applies to ALL sectors if thresholds met

Incorrect: "This is our first year meeting SECR thresholds, so we are exempt."

• Problem: No first-year exemption exists

Incorrect: "We consumed less than 40,000 kWh of electricity, so we're exempt."

• Problem: The 40,000 kWh threshold includes ALL energy (electricity, gas, transport fuels, etc.). If you have gas heating, you likely exceed this.

Correct low-energy exemption:

"The company's total UK energy consumption during the reporting period was 32,000 kWh, below the 40,000 kWh threshold. Accordingly, under the SECR regulations, the company is not required to report detailed energy and emissions data."

Only claim this if you've actually verified total energy across all sources is under 40,000 kWh—not just electricity.

Mistake 9: Poor Formatting or Unclear Presentation

The error: SECR information buried in unrelated sections, poor labeling, or confusing structure.

Why it happens:

• Trying to minimize space by incorporating SECR into other sections
• No clear headings or structure
• Mixing SECR data with non-SECR information

How to avoid:

• Dedicated SECR section in Directors' Report with clear heading: "Streamlined Energy and Carbon Reporting (SECR)"
• Logical structure: Energy consumption → Emissions (Scope 1, Scope 2) → Intensity ratio → Energy efficiency actions → Methodology
• Use tables for quantitative data (easier to review)
• Clear units: Always specify kWh for energy, tCO2e for emissions

Example of poor formatting:

Text buried in a paragraph:

"Various energy efficiency measures were undertaken and the company used 450,000 electricity and 200,000 gas last year with emissions calculated at approximately 120 tonnes which is about 2.1 per employee using the government factors."

Problem: Illegible, units unclear, no structure. Difficult for Companies House reviewers (human or automated) to verify completeness.

Correct formatting:

Streamlined Energy and Carbon Reporting (SECR)

In accordance with the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018, the company reports the following for the year ended 31 March 2026:

Energy Consumption (UK operations)

• Electricity: 450,000 kWh
• Natural gas: 200,000 kWh
• Total: 650,000 kWh

Greenhouse Gas Emissions

• Scope 1 (natural gas): 40.6 tCO2e
• Scope 2 (electricity): 86.9 tCO2e
• Total: 127.5 tCO2e

Intensity Ratio

• 2.1 tCO2e per employee (61 FTE)

Energy Efficiency Actions [Narrative of actions taken]

Methodology Emissions calculated using UK Government GHG Conversion Factors 2025.

This is clear, complete, and easy to verify.

Mistake 10: Including Inappropriate Content

The error: Adding non-SECR information or inappropriate claims in the SECR section.

Why it happens:

• Confusing SECR with broader CSR or sustainability reporting
• Making unsubstantiated claims about "carbon neutrality" or offsetting
• Including Scope 3 data without clearly distinguishing it from mandatory Scope 1/2

How to avoid:

• Keep SECR focused: Report only what's required (Scope 1, Scope 2, intensity ratio, efficiency actions)
• Separate voluntary from mandatory: If you report Scope 3 or other voluntary data, clearly label it as "additional voluntary disclosure"
• Avoid marketing language: SECR is regulatory compliance, not a branding opportunity

Example of inappropriate content:

"Scope 1 emissions: 45 tCO2e. Scope 2 emissions: 80 tCO2e. However, the company is carbon neutral through the purchase of gold-standard carbon offsets."

Problem: SECR requires reporting actual emissions. Carbon neutrality claims (which are complex and often controversial) don't belong in mandatory compliance disclosure and may invite scrutiny.

Better approach:

"Scope 1 emissions: 45 tCO2e. Scope 2 emissions: 80 tCO2e. Total: 125 tCO2e."

If you want to discuss offsetting, do so in a separate voluntary sustainability section outside of SECR.

Example of unclear voluntary reporting:

"Total emissions: 200 tCO2e, including business travel and waste disposal."

Problem: Business travel and waste are Scope 3 (not required). Mixing them with Scope 1/2 without clear breakdown creates confusion.

Correct approach:

"SECR mandatory disclosure: Scope 1 and 2 emissions total 125 tCO2e (as detailed above). In addition, the company has voluntarily estimated Scope 3 emissions from business travel (60 tCO2e) and waste disposal (15 tCO2e), recognizing these are not required under SECR but provide stakeholders with a fuller picture of our carbon footprint."

What If Your SECR Has Already Been Rejected?

If you've received a rejection notice from Companies House, don't panic. Follow these steps:

Step 1: Understand the Specific Deficiency

Read the rejection notice carefully:

• What specific issue did Companies House identify?
• Is it missing data, incorrect format, or unclear disclosure?

Step 2: Gather Missing Information

If data is missing:

• Obtain missing energy bills or fuel data
• Recalculate emissions if needed
• Prepare corrected SECR disclosure

Step 3: Correct the Directors' Report

• Add or amend SECR section in Directors' Report
• Ensure all mandatory elements are present (energy, Scope 1, Scope 2, intensity ratio, energy efficiency narrative)
• Have corrected accounts reviewed by accountant or compliance specialist

Step 4: Resubmit Promptly

• Companies House typically allows 14 days to correct and resubmit
• Don't delay—late filing penalties may apply if you miss your original deadline
• Submit corrected accounts via Companies House WebFiling or through your accountant

Step 5: Prevent Future Rejections

• Document what went wrong for next year
• Implement checklist or process improvements
• Consider using automated compliance platforms (like Comply Carbon) to eliminate errors

How Comply Carbon Eliminates Rejection Risk

Comply Carbon's platform is designed to prevent every single one of these common mistakes:

Built-In Compliance Checks

• Completeness validation: Won't generate report until all mandatory data is provided
• Scope 1 and 2 verification: Prompts you to confirm all energy sources are included
• Automatic intensity ratio calculation: Calculates all common intensity ratios; you choose the most relevant
• Energy efficiency prompts: Guided questions help you document actions taken

Always-Current Conversion Factors

• Automatic updates: Platform incorporates latest UK Government conversion factors as soon as published
• No manual lookups: You never touch a conversion factor spreadsheet—calculations happen automatically
• Audit trail: Reports document which factor version was used

Format and Structure Guarantee

• Pre-formatted reports: SECR disclosures generated in Companies House-compliant format
• Clear sections: Energy, emissions, intensity ratio, narrative all clearly structured
• Professional presentation: Tables, headings, and layout match best practice

Quality Assurance Automation

• Sanity checks: Platform flags implausible data (e.g., emissions per employee 10x higher than sector norms) and prompts you to verify
• Year-on-year comparison: Highlights significant changes and asks for explanation
• Mandatory fields: Can't skip required elements—all must be completed to generate final report

Result: 100% Acceptance Rate

Over 200+ companies using Comply Carbon, we've maintained a 100% Companies House acceptance rate—zero rejections. Our automated compliance checks catch errors before you file, not after.

Best Practices Summary: Avoiding SECR Rejection

Before you file:

• Verify SECR applies (meet 2 of 3 thresholds)
• Gather complete energy data for full financial year (electricity, gas, transport fuels)
• Calculate Scope 1 and Scope 2 emissions using current UK Government conversion factors
• Calculate at least one meaningful intensity ratio
• Document energy efficiency actions (specific and substantive)
• Format SECR as dedicated section in Directors' Report with clear headings
• Have second person review for completeness and plausibility
• Cross-reference against this article's top 10 mistakes

When filing:

• Ensure SECR section is included in uploaded accounts
• Verify reporting period matches financial year
• Submit before statutory deadline (9 months after year-end for private companies)

After filing:

• Retain supporting documentation (bills, calculations) for 6 years
• If rejection notice received, address promptly (within 14 days)
• Learn from any issues to improve next year's process

Resources for SECR Compliance

• UK Government SECR Guidance: gov.uk/secr-guidance
• GHG Conversion Factors: gov.uk/ghg-conversion-factors
• Companies House: companieshouse.gov.uk
• Comply Carbon SECR Guide: Complete SECR Guide

Get It Right the First Time

Ready to ensure your SECR filing is accepted by Companies House without rejection or delays?

1. Check your requirements: Use our compliance checker to confirm SECR applies
2. See a compliant report: Review our sample SECR disclosure to understand the standard
3. Eliminate rejection risk: Upload your energy bills to Comply Carbon for automated, error-free SECR reporting

With Comply Carbon's built-in compliance checks and 100% acceptance rate, you'll never worry about Companies House rejection.

About Comply Carbon: We're the UK's leading automated SECR compliance platform with a 100% Companies House acceptance rate across 200+ customers. Our platform eliminates all 10 common SECR mistakes through automated validation, current conversion factors, and pre-formatted compliant disclosures. Get your SECR report right the first time—in 10 minutes instead of 10 weeks, for £1,999 instead of £15,000+ consultant fees.